Recommendations on the emergency preparedness for, response to and recovery from incidents

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1 Recommendations on the emergency preparedness for, response to and recovery from incidents Recommendations on the emergency preparedness for, response to and recovery from incidents Buncefield Major Incident Investigation Board a

2 Recommendations on the emergency preparedness for, response to and recovery from incidents

3 Recommendations on the emergency preparedness for, response to and recovery from incidents Recommendations on the emergency preparedness for, response to and recovery from incidents Buncefield Major Incident Investigation Board

4 Recommendations on the emergency preparedness for, response to and recovery from incidents Crown copyright This publication may be freely reproduced, except for advertising, endorsement or commercial purposes. First published 07/07. Photographs 1-4, 7, 8, 10 and 11 courtesy of Hertfordshire County Council Photograph 5 courtesy of the Fire Service College Photographs 6 and 9 courtesy of the Press Association ii Photograph 12 by Brian Howard, supplied by Hemel Hempstead Local History and Museum Society and the Dacorum Heritage Trust Limited

5 Recommendations on the emergency preparedness for, response to and recovery from incidents Contents Introduction 1 The Board s approach Scope of the recommendations Status of the recommendations The recommendations Assessing the potential for a major incident 7 Recommendation 1 Managing a major incident on site 8 Recommendations 2 9 Preparing for and responding to a major incident off site 13 Recommendations Recovering from a major incident 27 Recommendations Annexes 1: Terms of reference and progress 32 2: Members of the independent board 35 3: Devolved and equivalent administrations 36 4: Other major incidents causing extensive off-site damage 39 5: National Recovery Working Group terms of reference 41 References 45 Glossary 48 Further information 51 iii

6 Recommendations on the emergency preparedness for, response to and recovery from incidents Figure 1 An overview of the Buncefield site and adjacent business and residential communities before the incident iv

7 Recommendations on the emergency preparedness for, response to and recovery from incidents Introduction 1 This report sets out recommendations to improve both planning for emergencies and the effectiveness of the response to emergencies at Buncefield-like sites and other high-hazard industrial facilities regulated under the COMAH 1 regime. The recommendations are made by the independent Investigation Board, chaired by Lord Newton of Braintree, set up to supervise the investigation into the explosions and fires at the Buncefield oil storage depot, Hemel Hempstead, Hertfordshire on 11 December The Health and Safety Commission (HSC) directed the investigation using its powers under section 14(2)(a) of the Health and Safety at Work etc Act Item five of the investigation s terms of reference required us to make recommendations for future action to ensure the effective management and regulation of major incident risk at COMAH sites. This should include consideration of off-site as well as on-site risks and consider prevention of incidents, preparations for response to incidents and mitigation of their effects. 3 Our initial report, (Ref 1) published on 13 July 2006, identified four principal workstreams that would form the basis for our continuing work and developing recommendations. Those workstreams are: design and operations; emergency preparedness for, and response to, incidents; advice to planning authorities; and examination of the Health and Safety Executive s (HSE s) and the Environment Agency s (EA s) roles in regulating the activities on the Buncefield site. 4 This report concentrates on the second of these emergency preparedness and response. It builds on the broad conclusions set out in paragraphs of our initial report. This report also draws together information from other sources, such as the recommendations and reviews by many organisations with experience of planning for and responding to the Buncefield incident. In several areas, work is already underway that has the potential to meet these recommendations. We understand that Hertfordshire Fire and Rescue Service, Hertfordshire Resilience Forum, the Health Protection Agency and the Buncefield Standards Task Group (among others) are working on aspects of emergency preparedness and response, including aspects recommended in our initial report. We welcome the initiative of the sector, the Competent Authority and responders in taking this forward. 5 We wish to ensure that their work and experiences are shared by the widest possible audience. Our broad aim in making these recommendations is therefore to ensure that the lessons of Buncefield are used to catalyse improvement in emergency planning, response and recovery arrangements throughout Britain. We well understand that devolved administrations exist elsewhere in the UK and these regimes differ from England in some respects in relation to their legislative and structural arrangements. We expect the recommendations in this report will be 1 The Control of Major Accident Hazards Regulations 1999 (COMAH). These Regulations are enforced by a joint Competent Authority comprising HSE and the Environment Agency in England and Wales and HSE and the Scottish Environment Protection Agency in Scotland. 1

8 Recommendations on the emergency preparedness for, response to and recovery from incidents fully implemented throughout the UK and we anticipate the Competent Authority (CA) will ensure there is consistency of approach across the UK in the COMAH sector. Annex 3 attempts to explain some of the differences in the devolved administrations and we have reflected these in our recommendations as far as possible without sacrificing coherence. 6 The Buncefield incident caused no fatalities, perhaps fortuitously, but it had a huge impact on local residents and businesses, as well as on communities further away. The huge scale of the devastation, plus the extent of the work required to enable full recovery, highlights the need to learn all we can from the experience. Indeed, the incident also provides insights into what might have happened but did not, particularly in potential impacts on public safety and health, and on the environment. The Board s approach 7 We recognise that the need to reduce the risk of a major incident at fuel storage sites is the first priority. For this purpose our report on design and operation of fuel storage sites made recommendations to catalyse improvement in the fuel storage sector so that it is continually alert to the major hazard potential of its operations. (Ref 2) Therefore Recommendation 1 calls upon site operators and the Competent Authority to ensure they have identified all foreseeable major hazard incidents and associated emergency scenarios. Recommendations 2 9 address the plans and arrangements to contain a developing incident on site, should primary containment be lost. 8 The second priority is to ensure that the emergency preparedness and response arrangements are effective, because however much improvement is made in preventive measures there can be no guarantee that a major hazard incident will not occur. The recommendations in this report therefore follow closely on our design and operation recommendations. Indeed there is some overlap between them, reflecting the close relationship between planning to prevent an incident and planning to deal with its potential consequences if it occurs. There may be further overlaps with the last two workstreams mentioned in paragraph 3, on which work continues. 9 The Buncefield incident was a major test for contingency planning and for the new national arrangements introduced under the Civil Contingencies Act 2004 (CCA) from September Recommendations deal with planning and implementing an emergency response by those concerned. The impressive emergency response to Buncefield effectively relied on initiative and good working relations of the responders in dealing with an incident that had been unforeseen and therefore not planned for. The performance of the primary responders and support was outstanding and we commend all those involved in managing the incident response. Recommendations address the primary response to major incidents, including setting up a means of assessing the public health implications. 10 We also acknowledge the efforts of many organisations in the response to Buncefield and the great resilience of the local community and businesses in the ongoing recovery effort to bring the affected local community back to social normality. Recommendations address the recovery from a major incident with Buncefield-like consequences. 2

9 Recommendations on the emergency preparedness for, response to and recovery from incidents 11 Our recommendations address the need to improve emergency arrangements at local, regional and national levels. An important element is to ensure that emergency arrangements to meet the requirements of COMAH are fully integrated with those established under the Civil Contingencies Act Recommendations deal in particular with central government leadership in the planning for and early response to a major incident. Scope of the recommendations 12 In our report on the design and operation of fuel storage sites we said that as a minimum, the recommendations would address Buncefield-type sites as defined by the Buncefield Standards Task Group, 2 ie depots that store and transfer petroleum products on a large scale. However, in most areas of emergency preparedness and response, we consider that many of the lessons from this incident can be applied beyond fuel storage and distribution, including matters that should be addressed at the national level. Certainly this report should be carefully considered by all those with a responsibility for COMAH sites with a potential for violent explosions or large complicated fires. More generally, we encourage high-hazard industries, the Competent Authority and Category 1 and 2 responders 3 to consider the broader relevance of our findings so far. 13 Some of the recommendations are addressed to those who have legal duties to prevent and control major incidents. 4 In practice this will require close working with the regulators (the Competent Authority), who will also need to ensure the recommendations are implemented. Other recommendations apply to organisations, including central or equivalent government and local authorities, responsible for planning for and responding to incidents and for the maintenance and restoration of social and economic well-being. This report is mainly written in terms of the UK approach to civil contingencies and COMAH, but in places refers to bodies or approaches which reflect the arrangements in England, or England and Wales. The Board expects that the equivalent administrations will respond as appropriate in line with their responsibilities. 2 The task group comprises industry, members of the COMAH Competent Authority and primary responders. It was set up in the aftermath of Buncefield to respond to the incident and to the recommendations of the Buncefield Board. 3 Category 1 responders are organisations at the core of the response to most emergencies (eg emergency services, local authorities, NHS bodies). Category 1 responders are subject to the full set of civil protection duties under the Civil Contingencies Act Category 2 responders are other organisations that are likely to be involved in emergencies, such as utilities and transport companies. 4 COMAH requires operators of major hazard sites subject to the Regulations to take all measures necessary to prevent major accidents and limit their consequences to persons and the environment. Operators of top-tier COMAH sites (like Buncefield) are also required to submit written safety reports to the Competent Authority, and to prepare emergency plans to deal with the consequences of a major accident. Operators and others (including contractors, designers, and suppliers) also have relevant duties under the Health and Safety at Work etc Act 1974 and related regulations and under environmental legislation. 3

10 Recommendations on the emergency preparedness for, response to and recovery from incidents Status of the recommendations 14 In making these recommendations we recognise that work continues within industry, the Cabinet Office Civil Contingencies Secretariat (CCS), Hertfordshire Resilience Forum, the emergency services, the Health Protection Agency, the Environment Agency, the local authorities Dacorum and St Albans, and other Category 1 and 2 responders to improve the effectiveness of emergency preparedness and response. The Buncefield Standards Task Group has worked hard to identify and address issues in preparation for this report. Our recommendations are intended to support and complement these efforts. 15 We expect our recommendations to be implemented throughout the COMAH and (where necessary) the Civil Contingencies Act sectors and elsewhere as appropriate, and the emergency planning community. The Civil Contingencies Secretariat or its equivalents in Scotland, Wales and Northern Ireland should oversee this work, working with the Competent Authority (CA) as appropriate. We envisage that the CA and other emergency planners/responders will adopt the recommendations as the minimum necessary to comply with relevant legal requirements. The recommendations do not specifically call for changes to the law on the assumption that the existing legal framework is sufficient to ensure that necessary improvements are put in place. However, if this proves not to be the case in any respect, the relevant government departments/devolved administrations should draw up proposals for the necessary legal changes. 16 Where the recommended improvements are self-evidently necessary or where implementation is already intended, we expect the recommendations to be implemented without undue delay and for the relevant authorities to see this is the case. Arrangements should be made by both the Competent Authority and the relevant devolved administrations to ensure our recommendations are implemented consistently across both the Civil Contingencies Act and COMAH legislative regimes. Some recommendations call for reviews of existing arrangements and procedures and, particularly where this involves a multi-organisational approach, as in the work of the National Recovery Working Group, 5 this may involve longer timescales before robust plans can be implemented. It is essential to have clear timescales, understood and committed to by industry, the relevant government ministers, agencies and authorities, and emergency planners, against which progress can be measured and reported. 17 Where commitments have already been made or the improvements are unquestionably necessary we have not undertaken detailed cost benefit analysis. This applies to most of the recommendations, since many are already in hand by the relevant authority and the Buncefield Standards Task Group. We are exploring the costs and implications of some of the recommendations, and attempting to draw economic parallels with other serious explosion incidents that massively impacted the surrounding community. This includes the Danvers chemical plant explosion, Massachusetts, in November 2006, the Toulouse chemical explosion in September 2001 and the Enschede Fireworks disaster in May 2000 (see Annex 4). We are also examining the full economic costs of the Buncefield incident from the various sources available. 4 5 The National Recovery Working Group was established by the Secretary of State for Communities and Local Government led by Government Office for the North West. See Annex 5.

11 Recommendations on the emergency preparedness for, response to and recovery from incidents The recommendations 18 Our recommendations are grouped under the following four headings: Assessing the potential for a major incident (Recommendation 1) Managing a major incident on site (Recommendations 2 9) Preparing for and responding to a major incident off site (Recommendations 10 26) Recovering from a major incident (Recommendations 27 32) 5

12 Recommendations on the emergency preparedness for, response to and recovery from incidents Figure 2 Looking into part of the Buncefield site before the incident. Note the ground vehicles, large storage tanks, and occupied buildings. To the right are manifolds that distributed fuel around the site 6

13 Recommendations on the emergency preparedness for, response to and recovery from incidents Assessing the potential for a major incident 19 The recommendations under this and the next three headings are based on the conclusions set out in paragraphs of our initial report and on the findings of the first (Ref 3) and third (Ref 4) progress reports. They have also been informed by our discussions with key responders to the Buncefield incident and by several reports and recommendations (listed in References and Further information) prepared by responders on their experiences. We endorse many of those recommendations. Our design and operation report (Ref 2) set out recommendations to prevent the recurrence of incidents like that at Buncefield. Nevertheless, however much preventive standards are improved the possibility of a major incident remains. It is essential, therefore, to have in place effective emergency arrangements in the event of an incident occurring. 20 Operators of top-tier COMAH sites are required by law to prepare adequate emergency plans to deal with the on-site consequences of possible incidents and to provide information to enable local authorities to prepare emergency plans to deal with the off-site consequences. To be effective, these plans must be based on a full appreciation of the potential for major incidents. Before Buncefield a massive vapour cloud explosion at a tank farm was not deemed a credible major incident risk. Nor is it just a matter of vapour cloud explosions, as there is also the potential for significant fires affecting multiple storage tanks. 21 The key to both effective major hazard controls and to effective emergency arrangements is the adequacy of the operator s assessment of the major hazard potential of a site. Getting this right will be reflected in relevant documentation, such as the COMAH safety report and emergency plans, and in the arrangements themselves. Operators therefore need to take an integrated approach to assessing preventive and responsive needs. Recommendation 1 Operators of Buncefield-type sites should review their emergency arrangements to ensure they provide for all reasonably foreseeable emergency scenarios arising out of credible major hazard incidents, including vapour cloud explosions and severe multi-tank fires that, before Buncefield, were not considered realistically credible. The Competent Authority should ensure that this is done. (Ref 5: HRF Rec 2) 7

14 Recommendations on the emergency preparedness for, response to and recovery from incidents Managing a major incident on site 22 A key objective of the on-site plan should be to contain an incident on the site to minimise its effects, to limit damage and to protect people and the environment. Following the identification of all emergency scenarios arising out of credible incidents (Recommendation 1), the operator must put in place arrangements to respond to those scenarios. This includes preparing and putting into effect an onsite emergency plan to specify the response of those who work on the site in an emergency. In practice this work must be closely integrated with preparing the site safety report and with providing the local authority with the information it needs to prepare an off-site emergency plan. 23 Paragraph 78 of our initial report recommended operators to review their onsite emergency plans following Buncefield, where they had not already done so. Recommendations 2 and 3 build on this early response to the incident by asking the Competent Authority to support operators in improving the quality of their onsite plans. Currently, guidance to COMAH operators on preparing on-site emergency plans is not sufficiently aligned with the guidance to the Competent Authority for assessing the plans. Therefore, firstly a review of the existing COMAH guidance on emergency planning is required; and secondly plans should be reviewed in the light of the revised guidance. 24 Recommendation 4 asks operators to ensure they have fully competent staff available 24/7 to perform the requirements of the on-site plan and should bear in mind the nature and extent of any changes to the plans as a result of Recommendations 2 and 3. If sites are inaccessible out of hours, operators should have alternative means of getting on site, providing an inventory of what is on site and maintaining communications with the site if an incident occurs. 6 Figure 3 Surface pipelines within an oil fuel depot 8 6 The Competent Authority has published a methodology to determine if the emergency preparedness on site is sufficient. (Ref 6)

15 Recommendations on the emergency preparedness for, response to and recovery from incidents Recommendation 2 The Competent Authority should review the existing COMAH guidance on preparing on-site emergency plans. (Ref 7) This guidance needs to reflect the HSE s Hazardous Installations Directorate (HID) 7 Chemical Industries Division inspection manual used by inspectors to assess the quality of the on-site plan in meeting the COMAH Regulations. In particular, reference should be made to the need to consult with health advisors and emergency responders. (Ref 5: HRF Rec 1) Recommendation 3 For Buncefield-type sites, operators should review their onsite emergency plans to reflect the revised guidance on preparing on-site emergency plans as per Recommendation 2. The Competent Authority will need to check that this is done. Recommendation 4 Operators should review and where necessary revise their on-site emergency arrangements to ensure that relevant staff are trained and competent to execute the plan and should ensure that there are enough trained staff available at all times to perform all the actions required by the on-site emergency plan. (Ref 2: Recs 6 and 19) (Ref 8: FRS Rec 10) 25 The Buncefield incident exceeded the assessed worst-case event of a single tank fire. The two pump houses and their associated lagoons to the north and northwest of the site were rendered unavailable for use. Recommendation 5 therefore repeats Recommendation 12 of our design and operation report, for the sake of completeness. Recommendations 6 and 7 go further to ensure operators secure alternative arrangements in the event of primary response facilities being unavailable, for example, taking account of seasonal variations in available water supply. 8 Where operators depend on local services (eg the local Fire and Rescue Service) to provide alternative resources, they need to consult the local provider to identify any limitations on the availability of services. Any such limitations should be considered and addressed within the site s emergency planning arrangements. Recommendation 5 For Buncefield-type sites, operators should evaluate the siting and/or suitable protection of emergency response facilities such as the emergency control centre, firefighting pumps, lagoons or manual switches, updating the safety report as appropriate and taking the necessary remedial actions. (Ref 2: Rec 12) Recommendation 6 Operators should identify vulnerable critical emergency response resources and put in place contingency arrangements either on or off site in the event of failure at any time of the year and make appropriate amendments to the on-site emergency plan. This should include identifying and establishing an alternative emergency control centre with a duplicate set of plans and technical information. (Ref 8: FRS Rec 10) 7 HID is responsible for regulating and promoting improvements in health and safety, contributing to the overall HSC/E aim of reducing and controlling the major hazard risks present across certain high-hazard industries and sectors. 8 The main water source for fighting the fires at Buncefield was the Breakspear Lagoon, which may not have held sufficient water in the summer months. 9

16 Recommendations on the emergency preparedness for, response to and recovery from incidents Recommendation 7 For COMAH sites, if the operator relies on an off-site Fire and Rescue Service to respond, the operator s plan should clearly demonstrate that there are adequate arrangements in place between the operator and the service provider. The Competent Authority will need to check that this is done. Warning and informing the public 26 Communications to the local community are important to give adequate assurance that the site is well run and emergency preparations are realistic and reliable. Regulation 14 of COMAH requires the operator of an establishment to ensure that the public, in a public information zone (PIZ), 9 is supplied with information on safety measures at the establishment and on what to do in the event of a major incident at the establishment. Communications with off-site communities are required at least every five years, while a review is required every three years. More frequent communications may be needed for larger communities or where the population is transient. It is important to pay adequate attention to this function in a consistent way. Recommendation 8 therefore asks operators to review their approach to communicating with the public, including making provision for joint communications with local authorities and others. Such joint communications would reassure the public that all parties are working together; that operators will do all they can to prevent an incident or contain it on site; and that if a major incident should occur and they are affected, the local authority has plans in place to help and support them. Where complaints or reports are made by the local community, the site operator should respond within a reasonable time. This recommendation is closely linked with Recommendation 20. Figure 4 Inspectors discussing strategy and logistics 10 9 This area is determined by the Competent Authority by taking account of both the likelihood and effects of possible major incidents at the major hazard site. It is set on the basis that people outside it are not at significant immediate risk from major incidents (although they could be if the incident escalates). The PIZ does not cover areas where a major incident might cause only environmental damage.

17 Recommendations on the emergency preparedness for, response to and recovery from incidents 27 Recommendation 9 supports this more integrated process by ensuring that the COMAH guidance on warning and informing the public (Ref 7) is revised to give more advice on the frequency and form of communication, and that it is complemented by the CCA Emergency preparedness guidance on communicating with the public. (Ref 9) This will encourage the actions of the operators to be integrated with those of Category 1 responders in their duty to warn and inform the public. Recommendation 8 COMAH site operators should review their arrangements to communicate with residents, local businesses and the wider community, in particular to ensure the frequency of communications meets local needs and to cover arrangements to provide for dealing with local community complaints. They should agree the frequency and form of communications with local authorities and responders, making provision where appropriate for joint communications with those bodies. (Ref 8: HRF Rec 3) Recommendation 9 The Competent Authority should review the COMAH guidance to assist operators in complying with Recommendation 8 and should work with the Cabinet Office to integrate the COMAH guidance and the CCA Communicating with the public (Ref 9) guidance, so that communications regarding COMAH sites are developed jointly by the site operator and the local emergency responders. Figure 5 Firefighters train to assist casualties in the event of an emergency 11

18 Recommendations on the emergency preparedness for, response to and recovery from incidents Figure 6 An unusual shot of a section of the M1 evacuated and closed in the height of the emergency. This caused major, temporary transport disruption to this part of the UK 12

19 Recommendations on the emergency preparedness for, response to and recovery from incidents Preparing for and responding to a major incident off site 28 In spite of efforts to prevent a major incident or to contain an incident on site, the potential for an incident to have an impact beyond the site boundary remains. Given the scale of the Buncefield incident, the majority of our recommendations deal with the emergency response to and recovery from a major incident. Here the main focus is on the local authority, which has the legal responsibility to prepare emergency plans to deal with the off-site consequences of an incident at a top-tier COMAH site. However, other Category 1 responders under the Civil Contingencies Act 2004 the Health Protection Agency, Health Protection Scotland (and equivalent health bodies), Regional Resilience Teams in Government Offices in the Regions, the Civil Contingencies Secretariat, equivalent administrations and the Competent Authority also have key roles. To prepare an effective plan the local authority and others depend on accurate information from the operator about the nature of operations on site and their hazard potential. This underlines the importance of an integrated approach and close co-operation between the various parties involved. 29 The local authority also has wider emergency planning functions, particularly under the arrangements now being put in place to implement the CCA. These arrangements had a severe test at Buncefield and held up well, but there are numerous lessons to be learned on a national scale. Since incidents of this scale are rare, it is important to ensure that the learning from Buncefield is shared by everyone concerned. We are aware that several reviews have been made of the emergency response to Buncefield, but not all are widely known and there is a danger that some good points will be missed. We endorse many of these points in this report. The nationally applicable lessons of all these reviews must be brought together and made accessible to all. The Civil Contingencies Secretariat should consider publishing a consolidated summary of the lessons to emerge from major incidents of this sort and the steps that are being taken to address them. 30 Our recommendations deal mainly with the detailed planning for and implementation of emergency arrangements, including communications. First, however, Recommendations consider general arrangements at national level. In our initial report we noted that to learn lessons on the emergency response requires input from a large number of organisations, and this work requires a clear lead if the maximum benefit from our and other recommendations is to be gained. We also said that it will be part of the Board s ongoing work to establish a clear picture of the lead provided by central [and devolved] Government for first responders. 31 During the early days of the response to the Buncefield incident, there was a valuable ministerial role in providing a focus for informing Parliament about the progress of the response and giving public reassurance that all necessary resources were being deployed. (Ref 10) There was, however, a perception particularly among those directly affected that once the spotlight had moved on, central government lost interest. This was not supported by our findings but, as different ministers became involved, it was unclear who had the responsibility to ensure that problems arising were addressed. 32 There is good sense in maintaining flexibility in central response arrangements, as well as in ministers generally stepping back from close operational involvement. We see benefit, however, in reviewing how the ministerial role may best assist and complement that of the direct responders this is addressed in Recommendation

20 Recommendations on the emergency preparedness for, response to and recovery from incidents As well as keeping Parliament informed and reassuring the public as provided for in the current arrangements, we see an important role for a minister in ensuring the response works as intended and in providing the authority to clear any bottlenecks. It is also important to ensure from the start that attention is given to the need to plan for the return to social normality, though this may mean working with a different minister who would be involved for a longer term (see Recommendation 27). Finally, while we acknowledge the efforts by many groups to implement recommendations made by other agencies, their task will be made easier if a minister is nominated to ensure that lessons arising from an emergency are implemented. 33 The CCA recognises that COMAH requires emergency response arrangements to be in place and sensibly does not duplicate these requirements. Unfortunately, we have indications that some see the arrangements to comply with the CCA and with COMAH as being separate. This was never intended and would lead to wasteful duplication and a possible loss of effectiveness. Just as emergency arrangements should be integrated with preventive measures, so should COMAH emergency arrangements be fully integrated with those under the CCA. The CCA framework and supporting guidance provides a valuable resource in preparing COMAH onand off-site emergency plans. Recommendation 11 addresses this point. Recommendation 10 The Cabinet Office should initiate a review of the arrangements to identify a minister (and their devolved counterparts) and their role to complement and support the emergency responders following a major incident to ensure national arrangements work as intended and there is continuity of government attention throughout the response and recovery phases. The review should include communications, public reassurance, the interface with planning for a return to social normality (Recommendation 27), and arrangements to ensure that recommendations made following major incidents are implemented. Recommendation 11 The Civil Contingencies Secretariat, working with the Competent Authority, should ensure that COMAH emergency arrangements are fully integrated with those under the CCA with the aim of ensuring that major hazard events are dealt with consistently at all levels, from on site to national, in terms of planning, shared resources, and practical arrangements. The review should include, but not be limited to, confirmation that: response arrangements take account of devolved responsibilities; lead responsibility in government for ensuring emergency response arrangements at COMAH sites is dealt with consistently under COMAH and CCA; procedures and guidance are suitably aligned; and deployment of emergency equipment considers both COMAH and CCA sectors and sites The support to Buncefield from many parts of Britain was impressive, as was the donation of human and material resources. The firefighting, while led by the Hertfordshire Fire and Rescue Service, required a national response with a total of 32 Fire and Rescue Services attending in some capacity, building on established arrangements. Mutual aid was also required by other responders. However, initiative and generosity need to be supplemented by co-ordination at a national level for an incident of this scale to ensure the most effective deployment of resources.

21 Recommendations on the emergency preparedness for, response to and recovery from incidents Recommendation 12 deals with the need for national-level arrangements to provide emergency equipment, since a major incident will rapidly exhaust local stocks. We acknowledge the work done to date by Communities and Local Government (CLG), like the positioning of high volume pumps. This links with Recommendations 23 and 24. Further work is required to assess the cost implications of a national scheme for hardware against the benefits of greater public assurance that emergency equipment is readily available throughout the country to respond quickly to events and without randomly depleting regional resources. Recommendation 12 Communities and Local Government should complete and, where necessary, initiate an assessment of the need for national-level arrangements to provide, fund and maintain, emergency response equipment (such as high volume pumps, firefighting foam and specialist pollution containment equipment). The review could also consider criteria for allocation and use of this equipment across the UK. 35 It was clear from the many reports from Buncefield that insufficient guidance was available to primary responders on a number of critical early issues, such as how to assess the impact of the smoke plume on air quality. This is addressed at Recommendation 13. Decisions on whether to fight the fire or to allow it to burn out in a controlled fashion depend on the availability of such assessments and we urge the Environment Agency to complete the work in hand on the controlled burn strategy guidance (see paragraph 51). Recommendation 13 The Civil Contingencies Secretariat should review guidance to responders on assessing the extent of the impact of an incident at a COMAH site to ensure appropriate scales of response and resources are provided, at local, regional or national levels. Review of off-site emergency plans 36 Effective emergency response depends upon a clear and concise emergency and contingency plan, trained and experienced responders and a well-informed community. Recommendations focus on improving the off-site emergency preparedness and response. This primarily requires local authorities to review the effectiveness of their emergency plan and responders to review their training arrangements. 37 The primary need is for better guidance for local authorities and early responders to make effective plans for dealing with major incidents such as large explosions. During the development of the off-site emergency plan for Buncefield, there seems to have been little practical support or guidance for the local authority to understand the safety reports for the site, or on whom to consult about important knock-on effects of a major incident, such as the need for and consequences of closing schools and hospitals, threats to clean water and electricity supplies. Recommendation 14 calls for improved guidance to assist local authorities draw up effective off-site emergency plans. Recommendation 15 calls for measures to ensure arrangements are effective in practice. Both recommendations build on work already underway by the Civil Contingencies 15

22 Recommendations on the emergency preparedness for, response to and recovery from incidents Secretariat 10 and the Emergency Planning Society. 11 We commend this work and encourage its completion without delay. Recommendation 14 The Civil Contingencies Secretariat, working with the Competent Authority, should arrange for national guidance to local authorities to be prepared, addressing as a minimum the areas covered in Recommendation 15. Guidance should also address the competencies required for emergency planners, and be clear on the resources that may be demanded for an effective emergency planning function. The guidance should be a living document, ie periodically updated in the light of new knowledge of handling major emergencies. Recommendation 15 Local authorities should review their off-site emergency response plans for COMAH sites in line with the revised guidance produced in response to Recommendations 13 and 14, and in the case of fuel storage sites, to take account of explosions and multi-tank fire scenarios. The aim is to ensure plans contain the key information from relevant COMAH safety reports (without compromising the safety reports confidentiality), which should be provided by site operators following their reviews of arrangements under Recommendation 1. The review should include but not be limited to the following: input from trained and competent emergency planners following clear guidance; working in conjunction with Regional Resilience Forums, and their equivalents in Scotland and Wales, in preparing their off-site emergency plans to understand potential impacts on the Region. (Ref 10) The Local Resilience Forum structure encourages multi-agency co-operation and information sharing within a county. The Regional Resilience Forum, 12 and their equivalents, should determine where further consultation is applicable and determine how this is done within and across regions; working in conjunction with neighbouring local authorities in developing their off-site emergency plans and involving these authorities in training and in emergency exercises; extending co-operation beyond the statutory consultation distance (CD) supplied by HSE to take into account the worst possible impact of a major incident, in effect re-calibrating the public information zone, which conventionally aligns with the CD; The Civil Contingencies Secretariat has launched a programme of work to identify and disseminate good practice. This would be a viable route for disseminating good practice in preparing and responding to COMAH sites. For industry, the competent authorities must continue to collate and disseminate good practice nationally and internationally. 11 The Civil Contingencies Secretariat and the Emergency Planning Society aim to establish a set of core competencies designed to further enhance the professionalism of the workforce in the civil protection sector. By the end of 2008 a set of core competencies for professional emergency planning practitioners working in government and in public, private and voluntary sector organisations will have been drawn up. 12 The Regional Resilience Forums are established by each Government Office to discuss civil protection issues from the regional perspective and to create a stronger link between local and central government on resilience issues. Similar arrangements are made in the devolved administrations.

23 Recommendations on the emergency preparedness for, response to and recovery from incidents considering with other primary responders the fitness for purpose of the plans for the different tiers of the command and control structure (gold/silver/bronze); taking account, with appropriate expert input, of the local environment to identify what would be at risk and to identify the potential consequences. CCS and the Competent Authority, as the enforcing authority under COMAH, should ensure the reviews are carried out. 38 The public health impacts of Buncefield appear to have been minimal. (Ref 11) In our initial report we welcomed the establishment of a Health Protection Agency (HPA)-led working group aiming to construct frameworks and agreed working practices for any future post-incident sampling. We continue to await the completion of this work. We understand the Environment Agency may assume lead responsibility for the co-ordination of air quality monitoring following a major incident as they currently do for surface and groundwater (the extent and longevity of ground water contamination continues to be monitored by the Environment Agency). It is sensible that both HPA and EA should be actively involved in the development of the off-site plans by local authorities. Recommendation 16 HPA, HPS and NPHS (National Public Health Service) Wales, EA, SEPA and EHSNI (Environment and Heritage Service Northern Ireland) should provide local contact details to local authorities and Local Resilience Forums 13 (LRFs) to facilitate emergency plan development. This will ensure local authorities have clear consultation routes for the public health and environment aspects of their off-site emergency plans. (Ref 2: HRF Rec 5) 39 The voluntary services were invaluable in their assistance to the emergency responders. The WRVS (Women s Royal Voluntary Service) and Salvation Army provided catering and the British Red Cross supported the rest centre. Local retailers and suppliers of domestic goods are to be commended for their generosity in supporting the work of the voluntary services. The volunteer groups involved found that there is a need to raise the profile of the volunteer groups and what they can do to support an emergency response. Recommendation 17 highlights the need for emergency plans to incorporate arrangements to meet the welfare needs of responders, an area where the voluntary sector has an important contribution to make. Recommendation 17 Local authorities should ensure their off-site emergency plans give due consideration to meeting the welfare needs of responders, including arrangements to provide food and drink and toilet and washing facilities, on all shifts. This will also need to include guidance on rest breaks and the provision of accommodation for responders from outside of the local area. Plans should make provision for the contribution of the volunteer community in attending major incidents in the welfare and other supporting roles. (Ref 8: FRS Rec 26) (Ref 5: HRF Rec 38) 13 The principal mechanism for multi-agency co-operation between all Category 1 and 2 responders in a local police area is the Local Resilience Forum (LRF). The aim of LRF is to facilitate fulfilment of the statutory duties of the members. The LRF is not a statutory body, but it is a statutory process under the Civil Contingencies Act

24 Recommendations on the emergency preparedness for, response to and recovery from incidents Figure 7 WRVS providing assistance to emergency service personnel during the response to the Buncefield explosions 40 Many, perhaps most, local authorities will need to revise their off-site emergency plans for COMAH sites in the light of our recommended review. Recommendation 18 calls on local authorities to take the necessary measures to bring their revised plans into effect. In taking evidence from responders in the aftermath of Buncefield, and considering the situation in other parts of Britain it was very clear to us that regular contact between responders greatly enhances the efficacy of the immediate response. Recommendation 19 calls on local authorities to test their (revised) arrangements in a practical way. Recommendation 18 In reviewing their off-site emergency arrangements for COMAH sites, revised in accordance with our recommendations, local authorities should identify the facilities, resources and actions that are critical to successfully respond to an emergency and should provide contingencies for Buncefield-type sites. Local authorities should review and where necessary revise emergency arrangements to ensure that relevant staff are trained and competent and that there are enough trained staff and resources to perform the actions required by the emergency plan at all times. Recommendation 19 Local authorities should ensure their revised off-site emergency arrangements for COMAH sites are tested within 12 months of production. Exercise scenarios based on real incidents should be compiled by CCS and the Competent Authority and available for multi-agency exercise development: All Category 1 responders should ensure their staff are trained within six months of production to deliver the emergency response. and 16) (Ref 5: HRF Recs 7, 14 18

25 Recommendations on the emergency preparedness for, response to and recovery from incidents Local authorities should arrange for councillors and elected members to have awareness training regarding their role in planning for, responding to and recovering from emergencies to effectively represent their communities During the early stages of Buncefield, there was some disappointment with the lack of availability of up-to-the-minute information on local radio and TV. Early advice to residents who were not evacuated was to go in, stay in, tune in, but it was not very clear where people should tune in to, and it was also unclear to us what information was relayed to the local media by those in strategic control of the response as part of the communications function. Recommendation 20 therefore calls for an assessment of compliance with current national standards. To assist in the emergency response phase, the operator and Local Resilience Forums should seek an agreement with local media to deliver key messages during an emergency, for example, along the lines of the BBC Radio Connecting in a Crisis (CIC) initiative, 15 where such arrangements are not already fully in place. These arrangements should be tested periodically. 42 There are no legal powers to force people to evacuate from their homes unless there is an act of terrorism. 16 Providing information to explain to the community that the decision to evacuate is not taken lightly and that it is always taken to protect life may assist in gaining support for evacuation. Communications to the community should include what they have to do and where they should go, how they can keep informed and how they will be notified when it is safe to return. Local authorities, working with the police, should consider how to secure both council and privately owned properties that may be vulnerable because of smashed windows and provide the necessary information to occupiers. Recommendation 20 Local Resiliance Forums and devolved equivalents should assess and advise operators, local authorities and the Competent Authority on the effectiveness of communications with residents, local businesses, dutyholders and the wider community in the event of a major incident. The assessment should use an agreed standard in line with CCA2004 guidance Communicating with the public (Ref 9) and include arrangements with local media to avoid conflicting advice being received, and to ensure key messages are transmitted. 14 Training is available at the Emergency Planning College, Easingwold 15 Connecting in a Crisis is a BBC initiative to help ensure that the public has the information it needs and demands during a civil emergency. It sets out to encourage emergency planners to work more closely with broadcasters in the preparation of strategies for communicating essential information. See 16 Generally speaking, the police do not have specific statutory powers to enforce a request or order to leave an area. The main exception to this is in relation to acts of terrorism where there are statutory powers to cordon off areas and it is an offence to fail to comply with an order to leave a cordoned area immediately. Evacuation may also be enforced under the Public Health Act 1984 if it is necessitated by infection or disease. (Ref 12) 19